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Sanctions watch

Every incident where a lawyer got caught filing AI-fabricated citations. The Hall of Shame.

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858
Incidents tracked
265
Incidents in 2026
$2,417,608
In fines, where reported
214 of 858 report an amount

The curve

Incidents per month

Last 18 months of published incidents, by the date of the court's order.

Apr 2025 Sep 2026

Charting 450 of 858 incidents; the rest are undated or fall outside this window.

Blamed by name

ChatGPT 151 Claude 9 CoCounsel 8 Copilot 8 Gemini 8 Lexis+ AI 6 AI-assisted legal software 4 Westlaw Precision 4 ChatGPT-4o 2 ChatOn 2 Eve 2 Google AI 2 LEAP 2 Perplexity AI 2 AI Overviews 1 Archie 1 Centient AI 1 ChatGPT-4 1 ClearBrief 1 CoCounsel, Westlaw Precision, Google Gem 1 Descrybe.ai 1 First Drafts 1 GPT-3.5 1 Ghostwriter Legal 1 Google Scholar 1 Grammarly 1 Grok 1 Irys 1 Legal Genius 1 LegalAI 1 MX2.law 1 OpenCase 1 Strongsuit 1 vLex Fastcase 1

Counts only incidents where the filing court or the reporting named the tool.

Hall of Shame

All Fined 251 Caught, not sanctioned 199 Warned 125 Referred to the bar 101 Reprimanded 86 Outcome unclear 56 Filing dismissed 37 Suspension 2 Upcoming sanction 1
Warned
Honolulu Deputy Corporation Counsel David Sgan filed a brief using AI-generated fake law in a major civil rights case, and Circuit Judge Karen Holma gave him only a scolding.
Honolulu Deputy Corporation Counsel David Sgan case · David Sgan · Hawaiʻi Circuit Court · HI
civilbeat.org ↗
The file →
  • David Sgan was identified by name in the article.
  • He used AI-generated fake law in a brief in a major civil rights case.
  • Judge Karen Holma let him off with a scolding, not a formal sanction.
  • Hawaiʻi Circuit Court, state of Hawaiʻi.
  • December 17, 2025; the article says he used AI-generated fake law.
Caught, not sanctioned
Kaʻōnohiokalā J. Aukai IV filed a brief with six flawed citations, including two fabricated ones, and Circuit Judge Kelsey Kawano accepted his apology and imposed no sanctions.
Kaʻōnohiokalā J. Aukai IV case · Kaʻōnohiokalā J. Aukai IV · Hawaiʻi Circuit Court · HI
civilbeat.org ↗
The file →
  • Kaʻōnohiokalā J. Aukai IV was the lawyer named in the article.
  • He filed a brief where all six citations were flawed, including two completely fabricated.
  • Judge Kelsey Kawano accepted the apology and declined sanctions.
  • Hawaiʻi Circuit Court, state of Hawaiʻi.
  • December 17, 2025; Aukai said the flaws were the result of AI hallucinations.
Caught, not sanctioned
Mark Valencia filed a brief with a non-existent case and a misstated Hawaiʻi Supreme Court decision; Judge Jordon Kimura found a Rule 11 violation and said he would sanction him later.
Valencia case · Mark Valencia · Hawaiʻi Circuit Court · HI
civilbeat.org ↗
The file →
  • Mark Valencia was the lawyer criticized in Hawaiʻi Circuit Court.
  • He submitted a brief with a fake case and a misstated Hawaiʻi Supreme Court decision.
  • Judge Kimura found a Rule 11 violation but had not yet set the sanction.
  • Hawaiʻi Circuit Court, state of Hawaiʻi.
  • December 17, 2025; Valencia blamed his associate and said the citations were AI-generated hallucinations.
Fined $500 ChatGPT
Michael Chambers filed a motion containing ChatGPT-generated fake case citations, and the court sanctioned him for the AI-made fabrications.
Arthur v. City of Hartford · Michael Chambers · U.S. District Court for the District of Connecticut · CT

Cases that don't exist

  • Mati v. City of Hartford
  • Smith v. City of Hartford
  • Johnson v. City of Hartford
nytimes.com ↗
The file →
  • Arthur v. City of Hartford; Michael Chambers was sanctioned.
  • He filed a motion with ChatGPT-generated fake legal citations.
  • The court imposed a $500 monetary fine.
  • U.S. District Court for the District of Connecticut.
  • The page says the fake cases came from ChatGPT.
Fined
A Commercial Division justice awarded fees under 22 NYCRR 130-1.1 against clients and counsel after AI-fabricated citations appeared in a summary-judgment opposition and sanctions opposition.
Ader v. Ader · Commercial Division, New York Supreme Court · NY
“Use of AI is not the problem per se.”
nlrg.com ↗
The file →
  • Ader v. Ader; clients and counsel were sanctioned
  • A summary-judgment opposition contained AI-fabricated citations
  • The court awarded fees under 22 NYCRR 130-1.1
  • Commercial Division, New York Supreme Court, New York County
  • The page says the sanctions motion response contained more than double the number of fake citations
Caught, not sanctioned
A relator’s legal team filed an expert report with fake citations and fabricated testimony, and the defendants sought sanctions and disqualification.
In re the relator’s legal team · U.S. District Court for the District of Utah · UT
“"The liability for using these new technologies without proper supervision falls squarely on the attorney. AI is a powerful tool, but it lacks professional judgment and a duty of candor to the court. Attorneys must remain the final check, or they will be held accountable for the errors it produces."”
qpwblaw.com ↗
The file →
  • A relator’s legal team in a Utah federal case
  • An expert report contained AI-generated falsehoods, including fake citations and fabricated testimony
  • The defendants moved for sanctions and disqualification; the article says the court permitted withdrawal but did not dismiss the issue
  • U.S. District Court for the District of Utah
  • No date was given; the article attributes the misconduct to a generative AI tool and alleges willful blindness
Fined $6K
A New Jersey federal judge sanctioned attorney Leo Maury Gordon for filing a hallucinated AI case citation and ignoring repeated warnings to verify his submissions.
Leo Maury Gordon · Leo Maury Gordon · U.S. District Court for the District of New Jersey · NJ
law360.com ↗
The file →
  • Leo Maury Gordon was sanctioned in the D.N.J.
  • He relied on a hallucinated AI case citation in a civil suit accusing Sean Combs and others.
  • The court ordered him to pay $6,000 and self-report to disciplinary authorities.
  • U.S. District Court for the District of New Jersey, New Jersey.
  • Law360 said the judge found he ignored repeated warnings to verify his filings.
Caught, not sanctioned ChatGPT
A practitioner filed a submission quoting a fictional Court of Appeal judgment generated by ChatGPT, and the judge said it wasted public resources.
LJY v Occupational Therapy Board of Australia · Queensland Civil and Administrative Tribunal · QLD
“the case simply does not exist”
nicholeslaw.com.au ↗
The file →
  • LJY v Occupational Therapy Board of Australia; a practitioner was involved.
  • A written submission quoted a fictional Court of Appeal judgment generated by ChatGPT.
  • No sanction is stated on the page; the judge said it wasted public resources.
  • Queensland Civil and Administrative Tribunal, Queensland.
  • 2025; the judge said 'the case simply does not exist' and 'caused a significant waste of public resources.'
Caught, not sanctioned
An AI-generated fake case was cited in a legal brief filed in his courtroom, and he found it did not exist.
State of Illinois v. Unknown · Jeffrey Goffinet · Williamson County court · IL
““People are going to use [AI], and the courts are not going to be able to be a dam across a river that’s already flowing at flood capacity,””
route-fifty.com ↗
The file →
  • Jeffrey Goffinet noticed a brief in his courtroom cited a nonexistent case.
  • The brief contained AI-generated fake legal material.
  • The article reports no sanction or penalty in this incident.
  • Williamson County, Illinois state court.
  • Last spring; Goffinet said courts must learn to coexist with AI.

Showing 191–200 of 858.

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